(125 days)
The AliveCor Heart Monitor is intended to record, store and transfer single-channel electrocardiogram (ECG) rhythms. The AliveCor Heart Monitor also displays ECG rhythms and detects the presence of atrial fibrillation and normal sinus rhythm (when prescribed or used under the care of a physician). The AliveCor Heart Monitor is intended for use by healthcare professionals, patients with known or suspected heart conditions and health conscious individuals. The device has not been tested and it is not intended for pediatric use.
The AliveCor Heart Monitor (the device) is the next generation of trans-telephonic (transmission by telephone) ECG (electrocardiogram) event recorders. The device utilizes the processing power of a mobile computing platform (MCP) while reducing the complexity of the electronics hardware associated with data acquisition and transmission. The AliveCor Heart Monitor can also analyze ECG signals and indicate the presence of noise, normal sinus rhythm and atrial fibrillation for each ECG recording.
Here's a breakdown of the requested information based on the provided FDA 510(k) summary for the AliveCor Heart Monitor:
Note: The provided document is a 510(k) summary, which often provides less detailed information about specific study designs and acceptance criteria than a full clinical study report. Therefore, some information might be missing or inferred.
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly state the acceptance criteria in terms of specific performance metrics (e.g., sensitivity, specificity thresholds) for atrial fibrillation or normal sinus rhythm detection. It generally states that "the collective results of the non-clinical testing demonstrate that the AliveCor Heart Monitor meets the established specifications necessary for consistent performance for its intended use."
However, it does reference AAMI/ANSI EC57: 2012 Testing and reporting performance results of cardiac rhythm and ST segment measurement algorithms. This standard typically outlines performance requirements for such algorithms, implying that the acceptance criteria would align with those specified in EC57. Without the full study report, the exact numerical thresholds for sensitivity and specificity are not available.
| Performance Metric | Acceptance Criteria (Inferred from EC57 & Document) | Reported Device Performance |
|---|---|---|
| Atrial Fibrillation Detection | (Likely sensitivity & specificity thresholds as per AAMI/ANSI EC57: 2012) | "validate the algorithms' performance" using EC57-recommended databases and captured data. (Specific performance values not provided in this summary) |
| Normal Sinus Rhythm Detection | (Likely sensitivity & specificity thresholds as per AAMI/ANSI EC57: 2012) | "validate the algorithms' performance" using EC57-recommended databases and captured data. (Specific performance values not provided in this summary) |
| Noise Detection | (Functionality as per device description) | "analyze ECG signals and indicate the presence of noise" |
| Overall Functionality | Meets established specifications for consistent performance | "the collective results of the non-clinical testing demonstrate that the AliveCor Heart Monitor meets the established specifications necessary for consistent performance for its intended use." |
2. Sample Size Used for the Test Set and Data Provenance
The document states: "The databases recommended by EC57 and data captured from the AliveCor Heart Monitor were used to validate the algorithms' performance."
- Sample Size for Test Set: Not explicitly stated. The EC57 standard recommends specific databases, but the exact number of ECGs used from these databases for validation is not provided in this summary.
- Data Provenance:
- Country of Origin: Not specified for the EC57 recommended databases. For "data captured from the AliveCor Heart Monitor," the country of origin is not specified, but the applicant is US-based.
- Retrospective or Prospective: Not explicitly stated. Database usage often implies retrospective data. "Data captured from the AliveCor Heart Monitor" could be either, but given the context of algorithm validation, it's likely a pre-existing dataset.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
This information is not provided in the 510(k) summary. When leveraging external databases like those recommended by EC57, the ground truth is typically established by expert cardiologists; however, the number and their specific qualifications are not detailed here.
4. Adjudication Method for the Test Set
The adjudication method is not specified in the 510(k) summary. If external databases were used, the ground truth within those databases would have been established through a documented adjudication process by the creators of those databases.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study focusing on human readers improving with or without AI assistance was not mentioned in this 510(k) summary. This submission appears to be focused on the standalone performance of the device's algorithms.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
Yes, a standalone performance study of the algorithm was done. The document explicitly states: "The non-clinical testing included... algorithm validation to demonstrate... the performance of the algorithms." The indications for use also state the device "detects the presence of atrial fibrillation and normal sinus rhythm," implying automated detection.
7. The Type of Ground Truth Used
The ground truth was based on expert consensus embedded within the "databases recommended by EC57" and "data captured from the AliveCor Heart Monitor." For rhythm analysis, this typically means human experts (cardiologists or electrophysiologists) manually reviewed and annotated the ECGs to establish the true rhythm diagnosis (e.g., atrial fibrillation, normal sinus rhythm).
8. The Sample Size for the Training Set
The sample size for the training set is not explicitly stated in this 510(k) summary. The document focuses on the validation of the algorithms, which uses a separate test set.
9. How the Ground Truth for the Training Set Was Established
The method for establishing ground truth for the training set is not explicitly stated in this 510(k) summary. It's generally assumed that similar methods to the test set (expert consensus) would have been used for training data, but no details are provided here.
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Re:
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
January 27, 2015
AliveCor, Inc. Albert Boniske Director of Regulatory Affairs 30 Maiden Lane, 6th Floor San Francisco, California 94108
K142743 Trade/Device Name: Alivecor Heart Monitor Regulation Number: 21 CFR 870.2920 Regulation Name: Telephone Electrocardiograph Transmitter And Receiver Regulatory Class: Class II Product Code: DXH, DPS Dated: December 15, 2014 Received: December 18, 2014
Dear Albert Boniske,
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in
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the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Kenneth J. Cavanaugh -S
for
Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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INDICATIONS FOR USE STATEMENT
510(k) Number (if known): K142743
Device Name: AliveCor Heart Monitor
Indications For Use:
The AliveCor Heart Monitor is intended to record, store and transfer single-channel electrocardiogram (ECG) rhythms. The AliveCor Heart Monitor also displays ECG rhythms and detects the presence of atrial fibrillation and normal sinus rhythm (when prescribed or used under the care of a physician). The AliveCor Heart Monitor is intended for use by healthcare professionals, patients with known or suspected heart conditions and health conscious individuals. The device has not been tested and it is not intended for pediatric use.
Prescription Use X (21 CFR Part 801 Subpart D) And/Or
Over the Counter Use ___X (21 CFR Part 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE; CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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510(k) Summary
510(k) Premarket Notification: K142743
General Information
Applicant: AliveCor, Inc.
30 Maiden Lane, 6th Floor San Francisco, CA 94108
Contact Person: Albert Boniske Director of Regulatory Affairs AliveCor, Inc. Phone: 415-795-9811 Fax: 415-397-0440
Date Prepared: September 22, 2014
DEVICE INFORMATION
Trade Name: AliveCor Heart Monitor
Generic/Common Name: Telephone electrocardiograph transmitter and receiver
Classification: 21 CFR§870.2920, Transmitters and Receivers, Electrocardiograph, Telephone, Class II
Product Code: DXH, DPS
PREDICATE DEVICE(S)
- . K140933 – AliveCor Heart Monitor
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510(k) Summary
Indications for Use
The AliveCor Heart Monitor is intended to record, store and transfer single-channel electrocardiogram (ECG) rhythms. The AliveCor Heart Monitor also displays ECG rhythms and detects the presence of atrial fibrillation and normal sinus rhythm (when prescribed or used under the care of a physician). The AliveCor Heart Monitor is intended for use by healthcare professionals, patients with known or suspected heart conditions and health conscious individuals. The device has not been tested for and it is not intended for pediatric use.
DEVICE DESCRIPTION
The AliveCor Heart Monitor (the device) is the next generation of trans-telephonic (transmission by telephone) ECG (electrocardiogram) event recorders. The device utilizes the processing power of a mobile computing platform (MCP) while reducing the complexity of the electronics hardware associated with data acquisition and transmission. The AliveCor Heart Monitor can also analyze ECG signals and indicate the presence of noise, normal sinus rhythm and atrial fibrillation for each ECG recording.
SUBSTANTIAL EQUIVALENCE
The proposed indications for use for the AliveCor Heart Monitor are substantially equivalent to the indications for use for the predicate device. The AliveCor Heart Monitor operates using the same technological characteristics for the same intended use as its predicate device. Each device records and stores ECGs and indicates the presence of abnormalities in the recording. The nonclinical testing results demonstrate that any differences in the technological characteristics between the subject and predicate device do not raise any new issues of safety or effectiveness. Thus, the AliveCor Heart Monitor is substantially equivalent to the predicate device.
Nonclinical Testing in Support of Substantial Equivalence Determination
All necessary performance testing was conducted on the AliveCor Heart Monitor to support a determination of substantial equivalence to the predicate device and demonstrate conformity to recognized standards
- AAMI / ANSI / IEC 62304:2006 Medical device software - software life cycle processes,
- ISO 14971: 2007 Medical devices -- Application of risk management to medical devices, and
- . AAMI/ANSI EC57: 2012 Testing and reporting performance results of cardiac rhythm and ST segment measurement algorithms.
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510(k) Summary
The non-clinical testing included software verification and algorithm validation to demonstrate the functionality of the software application and the performance of the algorithms. The databases recommended by EC57 and data captured from the AliveCor Heart Monitor were used to validate the algorithms' performance. The collective results of the non-clinical testing demonstrate that the AliveCor Heart Monitor meets the established specifications necessary for consistent performance for its intended use.
CONCLUSION
The results of the nonclinical testing demonstrate that the AliveCor Heart Monitor is substantially equivalent to the predicate device.
§ 870.2920 Telephone electrocardiograph transmitter and receiver.
(a)
Identification. A telephone electrocardiograph transmitter and receiver is a device used to condition an electrocardiograph signal so that it can be transmitted via a telephone line to another location. This device also includes a receiver that reconditions the received signal into its original format so that it can be displayed. The device includes devices used to transmit and receive pacemaker signals.(b)
Classification. Class II (performance standards).